As many US States and Canadian provinces approach legalization of cannabis, the question of regulatory oversight has become a pressing issue. While public awareness is mainly focused on issues like age restrictions and impaired driving, there is another practical question to consider: should cannabis be treated as a drug or a food product when it comes to safety? In the US, FDA governs both food and drugs, but in Canada, drugs are regulated by Health Canada while food products are regulated under the CFIA.There are many food safety hazards associated with cannabis production and distribution that could put the public at risk, but are not yet adequately controlled
Of course, there are common issues like dosage and potency that pharmaceutical companies typically worry about as the industry is moving to classifying its products in terms of percentage of chemical composition (THC, CBD, etc. in a strain), much as we categorize alcohol products by the percentage of alcohol. However, with the exception of topical creams and ointments, many cannabis products are actually food products. Even the herb itself can be brewed into teas, added to baked goods or made into cannabis-infused butters, oils, capsules and tinctures.
As more people gain access to and ingest cannabis products, it’s only a matter of time before food safety becomes a primary concern for producers and regulators. So when it comes to food safety, what do growers, manufacturers and distributors need to consider? The fact is, it’s not that different from other food products. There are many food safety hazards associated with cannabis production and distribution that could put the public at risk, but are not yet adequately controlled. Continue reading below for the top four safety hazards for the cannabis industry and learn how to receive free HACCP plans to help control these hazards.
Aflatoxins on Cannabis Bud
Just like any other agricultural product, improper growing conditions, handling and storage can result in mold growth, which produce aflatoxins that can cause liver cancer and other serious health problems. During storage, the danger is humidity; humidity must be monitored in storage rooms twice a day and the meter must be calibrated every month. During transportation, it is important to monitor and record temperatures in trucks. Trucks should also be cleaned weekly or as required. Products received at a cannabis facilities should be tested upon receiving and contaminated products must always be rejected, segregated and disposed of safely.
Photo courtesy of USDA ARS & Peggy Greb.
Chemical Residues on Cannabis Plants
Chemical residues can be introduced at several points during the production and storage process. During growing, every facility should follow instructions for applying fertilizers and pesticides to crops. This includes waiting for a sufficient amount of time before harvesting. When fertilizer is being applied, signs must be posted. After cannabis products have been harvested, chemical controls must be in place. All chemicals should be labelled and kept in contained chemical storage when not in use to prevent contamination. Only food-grade chemicals (e.g. cleaners, sanitizers) should be used during curing, drying, trimming and storage.
Without a comprehensive food safety program, problems will inevitably arise.There is also a risk of excessive concentration of chemicals in the washing tank. As such, chemical concentrations must be monitored for. In general, water (obviously essential for the growing process) also carries risks of pathogenic bacteria like staphylococcus aureus or salmonella. For this reason, city water (which is closely controlled in most municipalities) should be used with an annual report and review. Facilities that use well water must test frequently and water samples must be tested every three months regardless.
Pathogenic Contamination from Pest Infestations
Insects, rodents and other pests spread disease. In order to prevent infestations, a pest control program must be implemented, with traps checked monthly by a qualified contractor and verified by a designated employee. It is also necessary to have a building procedure (particularly during drying), which includes a monthly inspection, with no holes or gaps allowed. No product should leave the facility uncovered to prevent fecal matter and other hazards from coming into contact with the product. Contamination can also occur during storage on pallets, so pallets must be inspected for punctures in packaging material.
Furthermore, even the best controlled facility can fall victim to the shortcomings of their suppliers. Procedures must be in place to ensure that suppliers are complying with pest and building control procedures, among others. Certifications should be acquired and tracked upon renewal.
Pathogenic Contamination Due to Improper Employee Handling
Employee training is key for any food facility. When employees are handling products, the risk of cross-contamination is highest. Facilities must have GMP and personnel hygiene policies in place, with training conducted upon hiring and refreshed monthly. Employees must be encouraged to stay home when sick and instructed to wear proper attire (gloves, hair nets, etc.), while glass, jewelry and outside food must not be allowed inside the facility. Tools used during harvesting and other stages may also carry microorganisms if standard cleaning procedures are not in place and implemented correctly by employees.
As the cannabis industry grows, and regulatory bodies like the FDA and CFIA look to protect public safety, we expect that more attention will be paid to other food safety issues like packaging safety (of inks and labels), allergen control and others. In the production of extracts, for example, non-food safe solvents could be used or extracts can be mixed with ingredients that have expiration dates, like coconut oil. There is one area in which the cannabis industry may lead the way, however. More and more often, risks of food terrorism, fraud and intentional adulteration are gripping the food industry as the global food chain becomes increasingly complex. It’s safe to say that security at cannabis facilities is probably unparalleled.
All of this shows that cannabis products, especially edibles (and that includes capsules and tinctures), should be treated the same as other food products simply because they have the same kinds of hazards. Without a comprehensive food safety program (that includes a plan, procedures, training, monitoring and verification), problems will inevitably arise.
I couldn’t agree more. I’m so surprised that I don’t see more advertisements for food safety professionals for edibles.
I think you will see more regulation as it becomes more popular. It’s just like the beginning phases of alcohol, only people are afraid to speak up now because of social media.
Just a side note – CFIA is actually under the umbrella of Health Canada.
Good point – including the Food Directorate
Yes, the CFIA has been incorporated into Health Canada but CFIA inspectors are not yet actively inspecting cannabis facilities as edibles remain illegal in Canada (glossing over the fact that oils and even buds are edible and widely consumed orally). Hopefully this will all be resolved next year when edibles legislation is enacted.
The new version of ISO 22000:2018 Food safety management systems — Requirements for any organization in the food chain will be published in June. It is flexible enough for use by any link in the cannabis/food supply chain and a 1st class food safety management system standard.
I suspect that we’ll see little adoption of pure ISO 22000 and more SQF, BRC, and FSSC 22000 since the ISO standard is not a recognized Global Food Safety Initiative scheme. If companies are going to jump through the hoops of achieving a certification, they’ll go for one that carries the most weight. The exception might be companies looking to develop export markets to EU countries like Germany where production is still prohibited while licensed distribution is not.
Personally, I take some issue with the ISO standard in the way that critical control points can be assigned arbitrarily as opposed to the GFSI recognized schemes that require a more verifiable approach.
This is a good article. I am a food safety specialists in the cannabis industry and am glad to see more people concerned with food safety and cannabis. It’s very important.
I fully agree that infused edibles should be covered under identical food safety regulations as their ‘parent’, non-infused product. However, to base the concern on the cannabis plant itself is to miss the larger issue: state-level avoidance of any HACCP, cGMP, FSMA, or any other control plan beyond simple sanitation.
I have reviewed regulations for Colorado, Washington, and Maine (pending). In each of these states, the legalization committee either avoids calling an infused edible ‘food’, implicitly citing the adulterated food definition of 21 CFR 342. Essentially classifying edibles as ‘non-foods’ relegates them to a much lower standard, usually just kitchen sanitation. The December position of CFIA was very similar: ‘We are not contemplating edibles until 2019 and CFIA has not been funded [or assigned] to look at this issue.’
The classification also makes for easier political decisions. Invoking a ‘non-food’ classification removes any existing connections with state agriculture departments or state land-grant universities that work in food science. Severing connections avoids perceived conflicts with federal contracts or funding at the expense of safety.
The answer requires some intellectual honesty. We have to recognize the reality of the edibles market–in 2017, it exceeded $600 million, or between 200-300 million servings! Simply regulate as food and we will go a long ways towards protecting the public and building a legal market for cannabis.
We’ve developed HACCP plans for edibles manufacturers as well as primary producers.
The avoidance of the issue by FDA and CFIA is a short-term problem. With a federal commitment to national legalization of recreational edibles in Canada, it is likely that the CFIA will assume oversight responsibility far sooner that their FDA counterparts in the US. In fact, one can’t expect to see any practical movement by the FDA until federal prohibition ends. In the meantime, oversight responsibility defaults to state governments who have no experience with HACCP or FSMA so it seems that basic GMP certifications are best that can be hope for in the meantime.
I suspect we’ll see uniform requirements before long and the increased tax base should be able to cover the additional budget requirements needed by regulatory agencies without issue. My main concern is around the risk to public safety until the regulations are addressed.
A good article with excellent considerations. One suggestion for now is that the cannabis industry takes the lead in self-regulating/policing BEFORE government (in whatever form) gets deep into the issue. We have a chance to put in place the system that we would otherwise recommend. Current food systems in place would make good models, just as the regulations surrounding alcohol made a good starting point for many communities.
It would be wonderful to see the cannabis industry itself take the lead but I haven’t seen any meaningful movement in that direction. Many (I’d even venture to suggest most) of the people active in the industry are not aware of the nature of the hazards they face, how to control them, or what a critical control point is for example. There would need to be a solid knowledge base beforehand, which isn’t present in sufficient strength today but could perhaps come from the many who are migrating from traditional food industries. However, there are other problems that would make this very difficult. Human nature tends to follow the path of least resistance so voluntary standards are often ignored, there too many small players to meaningful represent an industry consensus, many come from the grey market where following regulations may not be well entrenched in the culture, and it only takes one bad apple to spoil the pie. Still, it would be really unfortunate if a serious outbreak of foodborne illness were to occur at this delicate juncture in the industry’s future, so it does make sense to try one’s best.
Hygiene and cleanliness should be practiced from the start to avoid aflatoxin and other harmful microorganisms from harming the final product. Whether it is used in smoking or edibles, we should comply with industry standards. Thanks for the great info!
I love reading your post! Thanks for the knowledge shared. Safety is always my priority!
I truly agree that employee training is the key to food facilities. When employees are handling products, the risk of cross-contamination is at its peak.
We hate aflatoxins in cannabis buds. That’s why we have to safeguard what we consume. Only trust reputable sources of cannabis. Beware.
I totally agree with this. As cannabis is used for medicinal purposes and other kinds of stuff, we should be very cautious in taking care of the plant.
Indeed handling chemicals must be observed with the utmost care, patience and cleanliness, this very important to avoid contamination or overuse or even misuse. Thank you for sharing.